Personal information is individually identifiable information about a person, namely information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or information relating to an identified or identifiable natural person which may be of private or sensitive nature. Under certain applicable laws identification of an individual
also includes any information which associates an individual with a persistent identifier such as a name, an identification number, persistent cookie identifier etc.
- Personal information does not include information that has been anonymized or aggregated so that it can no longer be used or to identify a specific natural person.
- Next – what and when do we collect personal information?
- We collect personal information from you and from any devices (including mobile devices) you use when you install or have the App installed (or pre-installed) on your device, register for an account with us, provide us with information such as your favourites, and travel habits, provide us information on a web form, run searches using our Services, update or add information to your account, or through correspondence you conduct with us.
More specifically we collect and use the following categories and types of information:
Personal information we collect automatically when you use our Services–
- Information collected when installing the App
- When you install the App (or have the App installed or pre-installed) on your mobile device, you are asked to register using your mobile number. Upon registration, Connexun will set up a user account associated with that mobile number and create a User ID for you. This is a unique identifier generated by us in accordance with this Privacy Notice, which is necessary in order for us to provide you with our Services. After installation of the App, we will collect and use your information, including the User ID, Geolocation and certain device information which includes your device ID or other unique identifier, unique device token, device type, operating system, all in accordance with this Privacy Notice. We may link this information with the account created in connection with your mobile device and User ID.
- We receive information from you when you access and use our Services, as follows: your IP address, your current location, your location preferences to use our services, our communications with you, information about your use and your interaction with our Services, and your in-app settings.
- Geo-Location Information and other Sensors data
- Connexun automatically collects location information such as your geo-location in order to provide you with our Services. When using the App we collect detailed location including GPS signals and other device sensors data such as gyro/oscilloscope sent by your mobile device for which the Service is installed and activated.
PLEASE NOTE THAT CONNEXUN COLLECTS YOUR LOCATION DATA EVEN WHEN YOU ARE NOT USING THE APP TO PERSONALIZE THE SERVICES AND MAXIMIZE YOUR USER EXPERIENCE AND TO DEVELOP AND ENHANCE OUR SERVICES.
- Connexun uses this location and sensor information to provide you with the Service and to utilize the location history to provide overlapping Point of Interests aligned with the user.
- Cookies & Similar Technologies
- Please take into consideration that certain portions of such above mentioned information may also be collected from your device or software, when the Services are running in the background, i.e. when they have been launched but are not actively used.
- Please keep in mind that most mobile devices and operating systems allow you to control or disable the use of certain collectable information including location services by applications, in the device’s settings menu.
Personal information you give us when you use our Services–
Generally, this category refers to any information, data or content you actively and voluntarily create, upload, or provide to use through our Services.
- Upon registering with Connexun with your mobile, you may also choose to share with us certain personal information, such as email address.
- email address can be used to connect your account to your original user id in-case you change the registered number.
Note – our Services are available to registered Users only, setting up an account allows you to enjoy the App without any limitations.
- Actively Provided Points of Interests (POI) Data
- In addition, you may choose to upload and share specific destinations and POIs such as your favourite destinations and POIs in order to expand our community services.
- Additional Content you Choose to Share with us when using the Services
- You may choose to upload to the Service User Content, such news, social events, and report data gaps or errors, and other types of content which you actively choose to provide. We also collect your responses to surveys we may send you on our behalf or on behalf of our partners.
- Additionally, you may choose to share with us your passport information, by using our in-app scanner that helps us to provide you with relevant results when travelling.
- In doing so, you consent to share with us your ethnic origin and other residential information available in the document.
Personal information collected from other sources–
- We may also collect personal information concerning you, from third parties who have assured us that they have obtained your consent for such provision of information or that you have freely and publicly provided. For example, we may collect and use demographic and other information that is publicly available in an applicable jurisdiction, additional contact information, credit check information, and information from credit bureaus, as allowed by applicable national laws.
- Special Uses of our Services–
- Please note that job candidates that may contact us or share with us certain information such as their CV, are subject to the Job Candidates general privacy laws.
- HOW WE USE YOUR INFORMATION
- Legal basis for use – We collect, process and use your information for the purposes described in this Privacy Notice, based at least on one of the following legal grounds:
- When Performing this Agreement: We collect and process your personal information in order to provide you with the Service, following your acceptance of these Terms; to maintain and improve our Services; to develop new services and features for our Users; and to personalize the Service in order to deliver better user experience. For example, we collect your location information in order to provide you with the content we think you will find most useful, based on your current location.
- With your consent: We ask for your agreement to process your information for additional specific purposes and you have the right to withdraw your consent at any time. For example, we ask for your consent to access your contacts, to provide you with people that share similar interest/origin and are near you;
- Legitimate interests: We process your information for our, or our third parties, legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our services; protecting against harm to the rights, property or safety of our properties, our users or the public as required or permitted by law; for the development and enhancement of our Services; for enforcing legal claims, including investigation of potential violations of this Privacy Notice; in order to comply and/or fulfil our obligation under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our Terms of Service.
Purpose of Use
We may use information that we collect about you for the following purposes:
- to provide you with and to operate the Service, including for aggregation, statistical and research purposes and creation and use of aggregated anonymous data;
- to personalize the Service and content provided to you, to customize your experience with the Services, to suggest you with geolocalized community information based on your preferences and to enable you to retrieve your information;
- to develop, improve and customize the Service, the experience of other users and the offering available through the Service;
- to be able to contact Users for the purpose of providing them with technical assistance, support, handle requests and complaints, and collect feedback in connection with our performance of the Services and in connection with public transportation needs;
- to send you updates, notices, announcements, and additional information related to the Service
- to be able to reply to User online queries in connection with performance of the Services; for customization and improvement of the Service’s accuracy and interface;
- to display or send to you marketing and advertising material when you are using the Service, including in accordance with the section titled ‘Direct Marketing’ herein and
- to comply with any governmental agencies’ legal requests or court orders, and/or with any applicable law, rule or regulation.
- to use the information to create statistical, aggregated or anonymous data which may be used at our discretion for any purpose.
- TO WHOM WE SHARE PERSONAL INFORMATION
We may share your personal information with third parties (or otherwise allow them access to it) only in the following manners and instances:
- Connexun has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting, database and server co-location services (such as AWS, Bluemix(IBM) and Compose), and mobile communication services (such as Twilio).
- Governmental/Law Enforcement Agencies and Legal Requests or Duties
- We may disclose or otherwise allow access to your personal information pursuant to a legal request, such as a subpoena, search warrant or court order, or in compliance with applicable laws, with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, counter terrorist financing verification requirements, fraud, or other wrongdoing.
- Protecting Rights and Safety
- We may share your personal information with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of Connexun, any of our Users, or any member of the general public.
- Connexun Subsidiaries and Affiliated Companies
- We may share personal information internally within our family of companies, for the purposes described in this Privacy Notice. In addition, should Connexun or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal information may be shared with the parties involved in such event.
For the avoidance of doubt, Connexun may share your personal information in additional manners, pursuant to your explicit approval. Additionally, we may transfer, share or otherwise use anonymized, aggregated or non-personal information in our sole discretion and without the need for further approval.
- WHERE DO WE STORE USER’S PERSONAL INFORMATION
- Information regarding the Users will be maintained, processed and stored by us and our authorized affiliates and service providers, and as necessary, in secured cloud storage, provided by our third-party service provider.
- While the data protection laws in the above jurisdictions may be different than the laws of your residence or location, please know that we, our affiliates and our service providers that store or process your personal information on our behalf are each committed to keep it protected and secured, pursuant to this Privacy Notice and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.
- You hereby accept the place of storage and the transfer of information as described above.
- We take great care in implementing and maintaining the security of Connexun’s Service and its User’s personal information. Connexun employs industry standard procedures and policies to ensure the safety of its Users’ personal information and prevent unauthorised access, disclosure and alteration of any such information. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorization controls. We cannot, however, guarantee that unauthorized access will never occur.
- COMMUNICATIONS FROM Connexun
- Connexun may contact you with information regarding our Services, or your use thereof. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, including changes to these Terms, transactions performed, service maintenance, etc. You will not be able to opt-out of receiving such service messages.
- Promotional and Surveys Messages (is it needed)
- In addition to communications that are an inherent part of our Services, occasionally we may also use your contact information to contact and notify you about new services and special opportunities or promotions we think you will find valuable and may also contact you in connection with surveys we conduct with respect to our services or in connection with public transportation issues either on our own behalf or on behalf of our partners. We may contact you through e-mail, phone (including text messages), push notifications, through the Services, or any other contact methods available to us, including with the help of our Third Party Services.
- YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
If you are an EU, EEA or Switzerland person and to the extent entitled under applicable law of your jurisdiction, you may contact us to exercise your right to access personal information, to request us to make corrections to your personal information that you have stored with us, to object to any form of processing, or to have such personal information deleted or exported
in a portable copy. For this, please send us an e-mail to firstname.lastname@example.org, or mail your request to the EU representative with a copy to Connexun Srl, Piazza Centro Commerciale 14 20090 Segrate (MI) Italy, and we will respond within a reasonable timeframe and in accordance with applicable laws and regulations.
- HOW LONG MAY WE KEEP YOUR PERSONAL INFORMATION
- We will retain your personal information for as long as you maintain an account or as otherwise necessary to provide you the Services. We will also retain your personal information as necessary to comply with our legal obligations, to resolve disputes, to prevent fraud and abuse, to enforce our agreements and/or protect our legitimate interests.
- Where we no longer need to process your personal information for the purposes set out in this Privacy Notice, or following your request to delete your Personal Information, we will delete or anonymize your personal information from our systems.
- To use our Services, you must be over the age of sixteen (16). Therefore, we do not knowingly collect personal information from minors under the age of sixteen (16) and do not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Services.
11.CHANGES TO THE PRIVACY NOTICE
- The terms of this Privacy Notice will govern the use of the Service and any information collected therein. Connexun reserves the right to change this notice at any time, so we encourage you to re-visit this page frequently. In the event of any substantial change of this notice, we will provide you with 7 days’ prior notice via any of the communication means available to us, or by posting notice of the change on the Site. After this 7-day notice period, all amendments to this Notice shall be deemed accepted and effective on both you and us. Except if and as stated otherwise, our most current Notice shall apply to all personal information described in such Notice.
- CONTACT US
- If you have any questions about this Privacy Notice or Connexun’s privacy practices, please contact us at email@example.com